CMS Proposed Reductions for Secondary Services

The federal agency suggested cutting payments for additional services provided during same-day outpatient visits.

Updated on Sept. 21, 2026 in Healthcare

Isometric editorial illustration of a sterile medical tray with surgical instruments on a clinical surface, representing healthcare policy. — The Centers for Medicare and Medicaid Services has proposed a new rule to reduce federal payments for secondary services performed during same-day outpatient visits. AI Illustration. Upload story photo >

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On July 16, 2026, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule in the Federal Register to reduce payments for secondary surgical or E/M services. The proposal seeks to limit compensation for multiple services performed on the same day by a single provider.

Why it matters

The proposal aims to curb perceived duplicate payments when physicians conduct multiple services during one patient encounter. Healthcare organizations argue the measure could result in significant financial losses for clinics and medical practices across the country.

The proposed rule establishes a 100% payment rate for the primary procedure, while secondary services performed on the same day would face a 50% payment reduction. A total of 150 healthcare organizations have formally expressed opposition to the CMS plan.

The players

Centers for Medicare and Medicaid Services

This is a federal agency within the U.S. Department of Health and Human Services that administers the nation's major healthcare programs.

American Medical Association

The American Medical Association is the largest association of physicians and medical students in the United States.

The details

Under the proposed framework, CMS would utilize the RBRVS Update Committee to determine new payment rates for outpatient services. This move follows a previous attempt by the agency in 2019 to implement a similar modifier 25 rule, which was eventually withdrawn after industry pushback.

CMS previously proposed and withdrew a similar rule in 2019.
The modifier 25 rule was published in the Federal Register on July 16, 2026.
The public comment period for the proposal concluded on September 20, 2026.
CMS is required to issue a final rule by November 1, 2026.

Market Landscape

This proposal alters the standard RBRVS Update Committee payment rate recommendations, reflecting a broader shift toward tighter federal control over medical billing and reimbursement structures. By targeting secondary service compensation, CMS is positioning itself to contain costs amidst widespread industry consolidation and rising operational expenditures.

The proposed reduction could lead to lower reimbursement rates for clinics, potentially forcing providers to reassess their billing practices for same-day services. Patients may encounter changes in how their doctors schedule multiple procedures to account for these federal payment limitations.

The takeaway

This proposal highlights the ongoing tension between federal cost-containment efforts and the operational viability of private medical practices. Providers should prepare for potential adjustments in practice management strategies if the policy is finalized later this year.